Group Therapy (97150) vs One-on-One Billing Under Medicare

On March 25, 2026, Team Rehabilitation Services, LLC agreed to pay $4,969,494 to settle False Claims Act allegations tied to how its clinics billed timed, one-on-one codes for sessions the government says were run as groups. The release describes the conduct as allegations Team Rehab agreed to settle; it reports no finding of liability.

The rule underneath those allegations is one sentence: a timed, one-on-one CPT code (97110, 97112, 97140, and similar codes) requires a single therapist’s direct, continuous or clearly separable attention to one patient for the minutes billed, while CPT 97150 covers simultaneous care to two or more patients whether or not they are doing the same activity. Almost every billing question a busy clinic will ask, whether 97110 can be billed while treating two patients, how to bill one-on-one and group on the same day, what a PTA changes, how many one-on-one units one clinician can generate per hour, comes back to that distinction.

Current as of September 2026.

What the Team Rehab and Chipley settlements allege

Team Rehab, which “operates approximately 140 physical therapy clinics in Michigan, Illinois, Indiana, Wisconsin, and Georgia,” resolved allegations that “from January 1, 2018, through December 31, 2024, Team Rehab knowingly and improperly submitted false claims to Medicare, Medicaid, TRICARE, the Federal Employees Health Benefits Program (FEHBP), and the United States Department of Veterans Affairs for time-based CPT codes for one-to-one physical therapy services even though those services occurred in a group setting where the provider did not maintain sufficient direct patient contact throughout the service to appropriately bill for those time-based CPT codes.”

A second 2026 settlement is worth knowing but is not a group-therapy case. On January 22, 2026, Absolute Physical & Aquatic Therapy, LLC, Chipley Physical Therapy, LLC, and two individual defendants agreed to pay $754,722.88 to resolve allegations that they “knowingly caus[ed] the submission of false claims for physical therapy services allegedly performed by Lorrie Laurel, a physical therapist, while she was outside the United States,” covering 503 claims between July 2019 and March 2024. The Chipley release states the legal posture in so many words: “The claims resolved by the settlement are allegations only and there has been no determination of liability.”

What counts as group therapy versus one-on-one care?

Medicare’s definition, from the Benefit Policy Manual: contractors pay for outpatient therapy “provided simultaneously to two or more individuals by a practitioner as group therapy services (97150). The individuals can be, but need not be performing the same activity. The physician or therapist involved in group therapy services must be in constant attendance, but one-on-one patient contact is not required.” The CPT descriptor, as Aetna’s clinical policy bulletin prints it, is “Therapeutic procedure(s), group (2 or more individuals).”

CMS’s worked scenarios draw the line on attention, not activity: “If the therapist is dividing attention among the patients, providing only brief, intermittent personal contact, or giving the same instructions to two or more patients at the same time, it is appropriate to bill each patient one unit of group therapy, 97150 (untimed).” One-on-one billing requires the opposite pattern, minutes “may occur continuously (15 minutes straight), or in notable episodes,” but “the manner of practice should clearly distinguish it from care provided simultaneously to two or more patients.”

Part B has no separate “concurrent therapy” category for two patients treated at once. CMS’s own SNF example makes the point: a therapist treating one Part A and one Part B resident in the same 30-minute session, giving each different activities without tracking identifiable one-on-one episodes, “would bill one unit of 97150 (group) for the Part B resident.” Divided attention across two patients under Part B is group time, regardless of the activity.

How Medicare counts minutes into units

For timed codes, the Claims Processing Manual sets the unit bands a treatment plan leans on constantly:

“It is not appropriate to count all minutes of treatment in a day toward the units for one code if other services were performed for more than 15 minutes.” The clock starts with treatment itself: “pre- and post-delivery services are not to be counted in determining the treatment service time.” See our 8-minute rule guide for the remainder-allocation logic on a day with multiple timed codes.

Can you bill 97110 while treating two patients?

Take a 30-minute block, one PT, two Medicare patients. From 10:00 to 10:12, the PT works one-on-one with Patient A on manual therapy (97140), 12 continuous minutes, while Patient B warms up independently. From 10:12 to 10:24, the PT switches to one-on-one neuromuscular re-education (97112) with Patient B for 12 continuous minutes, while A does a prescribed home program alone. From 10:24 to 10:30, the PT circulates between both with brief cues.

The compliant billing: Patient A gets 97140 x 1 unit (12 minutes) and Patient B gets 97112 x 1 unit (12 minutes). The 6 circulating minutes are billed to neither patient, and the independent exercise time is not billable, since CMS’s scenarios hold that “supervising patients who are exercising independently is not a skilled service.” Two variations are wrong. Billing both patients 2 units each claims 60 one-on-one minutes out of a 30-minute block, which one therapist cannot generate. Billing 97150 on top of the one-on-one units for the same period is also wrong, since Medicare bars billing “any CPT code for therapeutic procedures requiring direct one-on-one patient contact (CPT codes 97110 - 97542) with the group therapy CPT code (97150)” in the same time period. If the PT never tracks distinct one-on-one episodes and moves back and forth the entire 30 minutes instead, both patients get 97150 x 1 and no timed units.

How do you bill one-on-one and group on the same day?

A common pattern: 10:00 to 10:20, the PT works one-on-one with Patient A on therapeutic exercise (97110), 20 continuous minutes. 10:20 to 10:50, Patient A joins two other patients for a 30-minute balance group the same PT runs with constant attendance and divided attention (97150). Billed correctly, that is 97110 x 1 unit (20 minutes) and 97150 x 1 unit, with a bypass modifier, because the sessions are distinct and sequential rather than overlapping. A supporting treatment note reads: “97110 ther ex, one-on-one, 10:00–10:20 (PT). 97150 group, 10:20–10:50, 3 participants, PT in constant attendance. Timed code minutes: 20. Total treatment time: 50.” Billing 97110 x 3 for the full 50 minutes, or 97110 x 2 on the theory that the PT “checked in” during the group, is wrong.

CMS’s scenarios are explicit that same-day billing “is allowed, provided the CPT and CMS rules for one-on-one and group therapy are both met,” but “the group therapy session must be clearly distinct or independent from other services and billed using a -59 modifier.” Without it, “payment would be made for the lower-priced group therapy CPT Code.” The NCCI Policy Manual states the general limit: providers “shall not report more than one physical medicine and rehabilitation therapy service for the same fifteen-minute time period,” and those edits “may be bypassed with modifier 59 or XU if the 2 procedures of a code pair edit are performed in different timed intervals even if sequential during the same patient encounter.”

As of the v322r0 practitioner PTP edit file (CMS’s 2026 third-quarter release; the fourth-quarter file replaces it on October 1, 2026), 97150 pairs with several timed codes as a Column One/Column Two edit requiring that bypass modifier:

Indicator 1 means the pair can be bypassed with a modifier, placed on either code, when the sessions are genuinely distinct. Our NCCI edits guide covers modifier placement and how the quarterly file updates.

What does a PTA or aide change?

Run the same 30-minute balance group, but have a PTA run it while the PT treats someone else one-on-one. Each group member is billed 97150 x 1 with the CQ modifier, because the PTA furnished the group independently. CMS’s own billing example matches: “OTA – 20 minutes 97150 independent of the OT, OT – 20 minutes 97150 independent of the OTA, Total = 40 minutes of Group Therapy = 1 unit of 97150 is billed for each group member,” with the modifier applying “because the OTA provided more than the 10 percent time standard in this example.” This de minimis test applies “when the PT and the PTA or the OT and the OTA each independently provide minutes of the same untimed service,” and for those codes “1 unit is billed” regardless of the split. Our CQ/CO modifier guide works the 10 percent standard and resulting 85 percent payment rate in detail.

The PT’s own one-on-one patient in this scenario keeps the PT’s units with no CQ attached. CMS’s scenarios frame the same-time-period restriction as what “a therapist cannot bill,” and the team-therapy limit as two clinicians treating “the same patient(s)” at the same time; a PT and a PTA each treating different patients are each reporting their own minutes. If an aide runs the group instead, nothing is billable: “You cannot bill Medicare for the services of an aide that is supervised by the therapist or therapy assistant. Medicare Part B does not pay for the services provided by aides regardless of the level of supervision.” Students change the answer again: per the Benefit Policy Manual, group therapy may be billed when a student is present “in the room,” but “only the services of the therapist can be billed and paid under Medicare Part B.” See our PTA/OTA supervision guide for how general supervision, in effect in private practice since January 1, 2025, interacts with these rules.

How many one-on-one units can one therapist bill per hour?

This is the arithmetic the settlements turn on. One clinician cannot bill overlapping one-on-one codes, so one clinician can generate at most 60 one-on-one minutes per clock hour, total, across everyone on the schedule:

A clinic scheduling three patients per therapist-hour that averages three timed units per visit is claiming 9 one-on-one units, 135 minutes, out of a 60-minute hour, which is not possible for one clinician. Either PTA minutes are supplying the difference (and CQ needs to appear), or group time is being billed as one-on-one. CMS names the 10-minute version of this pattern directly. Its scenario is “billing of six units over a 60-minute period by providing direct one-on-one treatments to six patients for 10 minutes each.” Its answer: “Medicare’s expectation (based on the work values for these CPT codes) is that a therapist’s direct one-on-one patient contact time will average 15 minutes in length, for each unit,” and routine billing of that practice “would likely cause the contractor to question whether the services were reasonable and necessary.”

The dollar gap behind that arithmetic is worth seeing once, labeled for what it is: national unadjusted illustrations built from the CMS PFS relative value file (RVU26A, January 2026, conversion factor $33.4009; 97110 carries 0.87 non-facility RVUs and 97150 carries 0.54, so one unit is about $29.06 and $18.04 respectively), not CMS-published amounts, rounded once from the unrounded RVU arithmetic, and before MPPR or sequestration:

That spread, repeated across many clinicians and days, is the shape a settlement like Team Rehab’s takes on paper. The release does not say the figure was calculated this way; the arithmetic here is ours, meant to show why the audit test matters: for each clinician-day, sum the timed units billed across every patient and compare against scheduled treatment hours times four.

What the treatment note has to show

The treatment note requirements exist to make that arithmetic checkable after the fact. The note must state “total timed code treatment minutes and total treatment time in minutes.” And it must reconcile with the claim: “the billing and the total timed code treatment minutes must be consistent.” CMS’s documentation fact sheet names the most common audit gap directly: “missing total time for timed code treatment minutes and total treatment time,” fixed by “clearly document[ing] the total minutes for timed code treatment to support the number of units and codes billed for each treatment day.” For untimed codes, including 97150, the fact sheet says simply: “report 1 in the unit field.” Our documentation requirements guide covers the rest of what a compliant note needs.

What do commercial payers do differently?

Commercial policies generally adopt the same CPT definitions, one-on-one for timed codes, group for 97150, but each layers its own limits on top. UnitedHealthcare’s frequency policy (reviewed April 1, 2026) caps reimbursement at “a maximum of four timed codes (equivalent to one hour of therapy) per date of service”; 97150 is not on that capped list because it is untimed, and the policy notes it follows CMS on the “eight minutes of therapy services” minimum to bill one unit. UnitedHealthcare’s PT/OT policy (reviewed May 1, 2026) separately confirms CQ/CO applies “in accordance with CMS” for claims dated on or after January 1, 2020. Aetna’s clinical policy bulletin lists 97150 among related codes without stating a separate group-therapy coverage rule of its own.

None of these three policies restates Medicare’s expectation that 97150 be billed once per patient per day, and none restates the NCCI 97150 edits above; payers that license NCCI logic may run those edits on their own schedule, as covered in our NCCI modifier guide. Check the specific contract and the payer’s current reimbursement policy for unit limits and modifier rules on 97150 before assuming the Medicare answer applies.

The scheduling-density arithmetic above is simple; catching a visit that violates it before the claim goes out is not. PrismEHR lets organizations define their own billing rules, including minute and unit restrictions, enforced at the point of documentation and reinforced again at claim creation, and it does not prefill CPT units from the prior visit: units default to zero, so a unit count is something a clinician enters against the minutes actually documented. Paired with the per-unit logic in our CQ/CO modifier guide, that is what keeps a busy schedule from drifting into the pattern the Team Rehab settlement describes. See how it fits physical therapy practices.